58 replies to this topic

[Modarres]

Dear Esther,

OPRPs are not that hard to understand. They are just all the points that did not become CCP and are not included in prerequisite programs. We used to call them CPs earlier. They are called General control measures in Dutch HACCP, CPs in IFs and process monitoring in BRC.
Perhaps you can remember that in the earlier days of HACCP, companies used to have over 10 CCPs. Nowadays they only have 2-4 CCPs. The other 6-8s can mostly considered as OPRP.

You have to control them, but not that hard as a CCP.

Hi!
Sorry I found a question, if we put CP=OPRP, or from hazard analysis (severity multiple likelihood) just we conclude ccp/oprp, the we missed 22000 7.4.4: evaluation of control measures based on mention ed 7 criteria and defined parameters and logic method!

Thanks

[Charles.C]

Dear Modarres,

If you look through some other threads here, you will find that the statement CP=OPRP is considerably debated as to its acceptability. The term “CP” is not used in the 22000 standard and its precise interpretation has a large range of meanings in practice, [try searching this forum ]. If you wish one (negative) example, the Procert website (managed by one of ISO 22000 standard “design” members) contains examples illustrating an opposing scenario, ie OPRP = CCP but lacking certain characteristics, eg continuous monitoring. Additionally, the concept of OPRP was, supposedly, originally formulated for items considered to be equivalent to CCPs but with unspecifiable critical limits. And yet again, the initial opening equality above is also probably correct in some situations.
The conclusion is that current usage probably includes a range of possibilities depending on yr particular application / preferred interpretation. My guess is that as long as yr methodology is validatable both in logic, with respect to the final product safety, plus satisfying the associated choice's specific requirements, an auditor will be happy. I hv seen occasional user comments here that some auditors expect to see a “closer” match to the full standard 7.4.4 (a-g) features but this is certainly not a uniform expectation. Pragmatically speaking, the choice should probably minimise the number of CCPs and OPRPs as far as possible. Have you seen the current thread where TonyC is developing a model presentation for yoghurt ?

Yr comment regarding 7.4.4 is not incorrect but its implementation also requires interpretation within the context of the guidance document 22004. The latter implies / confirms that considerable flexibility is possible within the decision procedure for oprps / ccps, eg the final relative numbers are “up-to-you”!! (not sure if this was the strictly intended meaning).

I am not an auditor so any practitioners here please feel free to disagree any of the above.

Rgds / Charles.C

PS, the above also suggests that the last line of yr quoted earlier post may also be of substantial debate.

PPS - Sorry if i pre-empted other replies, hopefully Madam A. D-tor will also post her own response shortly but haven't seen her here for quite some time.

[Modarres]

Thank You Dear Charles

We know PRPs, OPRPs and HACCP Plan are 3 priority strategies for run Control Measures.
ISO 22000 requires:

• Based on the hazard assessment... combination of control measures shall be selected...
• The control measures selected shall be categorized as to whether they need to be managed through operational PRP(s) or by the HACCP plan.
• The selection and categorization shall be carried out using a logical approach that includes assessments with regard to the following: a)....g)...
• The methodology and parameters used for this categorization shall be described in documents, and the results of the assessment shall be recorded.

So an organization, a consultant or auditor shall :

• categorize control measures;
• use a logical approach for this categorizing;
• consider requirements a-g for this categorizing;
• have a methodology for this categorizing;
• use parameters in categorizing methodology...

That's all....

[Charles.C]

Dear Modarres,

I am no expert on ISO legalities but I believe that ISO 22004 supercedes 22000.

The consequence is that in 7.4.4, some of the "shall" >> "may"

To put it another way, ISO soon realised it had made a (textual) mess of the first version.

Rgds / Charles.C

[Modarres]

Dear Modarres,

I am no expert on ISO legalities but I believe that ISO 22004 supercedes 22000.

The consequence is that in 7.4.4, some of the "shall" >> "may"

To put it another way, ISO soon realised it had made a (textual) mess of the first version.

Rgds / Charles.C

Dear Charles,

As an ISO 22000 tutor, lead auditor, consultant and national standard developer, I know "should" = it is recommended, Ought to and "shall" = Is to, Is required to, It is required that, Has to, Only…..is permitted, It is necessary.

[Charles.C]

Dear Modarres,

It is good to have a real auditor taking part in the discussion. Yr English is impeccable.

I only hv close experience of BRC, their “shall” appears to be approximated by “somehow”.

As you, I think, intimated, ISO 22004 contains almost all “shoulds” (+ a few "mays" in important places). So, two docs from one extreme to the other (perhaps also because 2nd one is a “Guidance”, albeit a powerful one?).

I can understand that, as an auditor, you must have some guideline as to the minimum expectations for an auditee to satisfy the requirements of the 22000 standard. Yr choice for 7.4.4 appears to be the maximum. (not a criticism, just an observation).

Does this mean that you consider the 22004 document has not altered or diminished the original scope width of section 7.4.4 or simply that you prefer to maintain the maximum possible detail anyway ? The latter option should certainly minimise audit arguments.

IMO, one would certainly hope that the auditing profession has a “fairly” uniform set of assessment criteria. How was yours decided, globally/company speaking ? Just curious since I have met so many similar (non-ISO) discussions on traditional HACCP, notwithstanding the various Codex steps to help define things, unless one is in USA of course. The sad philosophy of ISO seems to be that they will never, ever, give examples. OK, plagiarism is a risk but widespread confusion is even worse IMHO. Of course, you may not share the last opinion, economically speaking.

Rgds / Charles.C

[Erasmo]

Simon

We are all cynics - ISO 22000 was and still is an incomplete and confusing standard which in my view complicates Haccp. (Lots of chat on the forum already on this topic!) BSi had the foresight to fill the gap realising that you cannot have an effective haccp system unless it is built on suitable pre-requesties so credit to them.

I don't think that ISO had any choice but to fill the gap and used PAS 220 which had already been developed and had gained some credibility. I view this as a positive step which can only help the credibility and wider acceptance of ISO 22000. (at least in manufacturing).

Ken

Well, I don’t think so. ISO-22000 is a Management System Standard (Not a specification; that’s why is not an ISO/TS document. TS=Technical Standard). PAS220 is also a specification (Publicity Available Specification 220). A Management System Standard HAS to be GENERIC because needs to comply with guide ISO-72. ISO-22000 cannot make specifications or level performance by definition and a good auditor does not need PAS-220 to raise a NC if he/she sees a deficiency in one PRP. (In fact: I’m an ISO-9001 auditor in the food sector and several times I have to document a NC in PRP’s; those are sometimes related with pest control, CIP, Allergens, etc. etc. etc…) and I can do that without a specification.

Also, ISO-22000 does not complicate HACCP; it is a part of it. All management system standards have the continuous improvement cycle (Plan-Do-Check-Act). The HACCP methodology only has the “planning” section (the 12 steps) … that’s why ISO-22000 has 2 sections related with “Verification”: 7.8 “Verification Planning” Step 11 in the HACCP, and 8.4 “FSMS Verification” not included in the Codex.

[Charles.C]

Dear Erasmo,

I was rather confused by –

Also, ISO-22000 does not complicate HACCP; it is a part of it.

I think you mean HACCP is a part of ISO 22000 ? .

Slightly OT to your post but, IMHO, the content in ISO 22000 relating to implementation of verification (I presume this is the Deming “Do” [I hate the PDCA cycle!]) is, although present, very weakly presented. And similarly validation. The degree of “weakness” is illustrated IMO when you compare 22000 to the clarity of the “guidance” in ISO 22004. This is presumably not by accident.

Personally, since ISO appear determined not to revise the original version of the Standard, I think it would have been justifiable to append footnotes at numerous places in ISO 22000 recommending users to appropriate sections of ISO 22004 in “case of confusion”. But I suppose this would have been “credibility” harakiri.

Rgds / Charles.C

[Tony-C]

a good auditor does not need PAS-220 to raise a NC if he/she sees a deficiency in one PRP. (In fact: I’m an ISO-9001 auditor in the food sector and several times I have to document a NC in PRP’s; those are sometimes related with pest control, CIP, Allergens, etc. etc. etc…) and I can do that without a specification.

True - but ISO 22000 does reference PRP(s) .............. consider ...... Codex Alimentarius Commission (Codex) principles and codes of practices, national, international or sector standards.

I don't think you can get away from the fact that ISO 22000 does complicate HACCP in that it requires categorisation of control measures into OPRP's or those controlled in the HACCP plan. Some would say although it is more complicated it is a more thorough approach to HACCP implementation.

Regards,

Tony